Ruth E. Neal - Page 5

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          spent little on herself, and essentially all of petitioner’s                  
          income in each year was spent on family expenses.                             
               Other than a mandatory State retirement fund to which                    
          petitioner contributed, petitioner does not have significant                  
          savings.                                                                      
               Using his income, Alimam generally paid the other half of                
          the monthly mortgage, the household utility bills, payments due               
          on the various cars he purchased, the payments due on                         
          petitioner’s one car, and his many personal expenses.                         
               Throughout their marriage, petitioner and Alimam maintained              
          separate checking accounts, and generally, the monthly mortgage               
          payments were made with checks written by Alimam.                             
               In 1989, Alimam filed for bankruptcy.  Petitioner also                   
          signed the bankruptcy petition.                                               
               At the time of the above bankruptcy, Alimam inaccurately                 
          told petitioner that the above bankruptcy and their poor                      
          financial situation were caused by various tax shelter                        
          deductions, which Alimam had claimed on their joint Federal                   
          income tax returns and which had been audited and disallowed by               
          respondent, resulting in large tax deficiencies.  In fact, Alimam             
          and petitioner’s bankruptcy and tax problems related                          
          significantly to unpaid taxes attributable to Alimam’s income                 
          from his medical practice.  Around the same time, petitioner had              
          heard from friends and medical colleagues that they also had                  






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